Ob-~ B29 STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioner, vs. Case Nos.: 2005-003062 2005-003060 CHRISTIE R. DEHERRA AND, CASTLE WORKS DRAFTING, Respondents. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, ("Petitioner"), files this Administrative Complaint before the Board of Architecture and Interior Design against CHRISTIE R. DEHERRA AND CASTLE WORKS DRAFTING, ("Respondents"), and says: | 1. Petitioner is the state agency charged with regulating the practice of architecture and interior design pursuant to Section 20.165, Florida Statutes, and Chapters 455 and 481, Florida Statutes. 2 The Department of Business and Professional Regulation I has jurisdiction over the unlicensed practice of architecture pursuant to Section 455.228(1), and Section 481.223(1)(a), Florida Statutes. 3. At all times material hereto, Respondents were not duly registered or certified to engage in the practice of architecture in the State of Florida pursuant to Chapter 481, Florida Statutes. 4, Respondents’ last known address is 1777 Tamiami Trail, Suite 406, Port Charlotte, Florida 34238. 5. On or about May 26, 2004, Respondents submitted exterior elevations to the Charlotte County Community Development Department in an attempt to comply with Charlotte County Design Standards, Ordinance 2003-023. 6. The exterior elevations were for a commercial project known as Exquisite Carpet & Interiors located at Highway 41, Port Charlotte, Florida. 7: The drawings submitted to the Charlotte County Community Development Department constitute the practice of architecture. 8. The owner of the project had to hire a Florida licensed architectural firm to complete the project because the drawings prepared by the Respondents were rejected. COUNT I 9. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 10. Section 481.223(1)(a), Florida Statutes, states that a person may not knowingly “practice architecture unless the person is an architect or a registered architect.” 11. Based upon the foregoing, Respondents, have violated Section 481.223(1)(a), _.... Florida Statutes, by practicing architecture when they were not the holder of a valid license. COUNT I 12. Petitioner hereby realleges and incorporates paragraphs one (1) through eight (8) as if fully set forth herein. 13. Section 481.219(2), Florida Statutes, requires a Certificate of Authorization to practice architecture services through a corporation, partnership, or under a fictitious name. Ww 14. Based upon the foregoing, Respondents have violated Section 481.219(2), Florida Statutes, by practicing architecture through Castle Works Drafting, without a Certificate of Authorization. WHEREFORE, Petitioner respectfully requests the Board enter an Order imposing an administrative fine not to exceed $5,000 per count, assess costs associated with investigation and prosecution, impose any or all penalties delineated within Section 455.227(2), Florida Statutes, and/or any other relief that the Board is authorized to. impose pursuant to Chapters 481 and 455, Florida Statutes, and/or the rules promulgated thereunder. . : BS . , Signed this __/7 day of Seppe mabe , 2005, ND %. DAVID K. MINACCI Smith, Thompson, Shaw & Manausa, P.A. 2075 Centre Pointe Blvd. Tallahassee, Fl 32308-4893 FL Bar No. 0056774 Ph: (850) 402-1570 Fax: (850) 402-1508 me Melos FILED Da Min Kody WAAL Department of Business and Professional Regulation LU ae DEPUTY CLERK Neyer? - CLERK WM Hlichole DATE 4-Al-2005 |

Docket for Case No: 06-000329